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UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
CASE NO.: 1:17-CV-00616
JANE DOE 43,
Plaintiff,
vs.
JEFFREY EPSTEIN, GHISLAINE MAXWELL,
SARAH KELLEN, LESLEY GROFF,
AND NATALYA MALYSHEV,
Defendants.
______________________________/
FIRST AMENDED COMPLAINT
Plaintiff JANE DOE 43, by and through her undersigned counsel, for her
claims against Defendants Jeffrey Epstein, Ghislaine Maxwell, Sarah Kellen,
Lesley Groff, and Natalya Malyshev, alleges upon personal knowledge with
respect to her own acts and status, and upon personal knowledge, information and
belief as to all other matters, as follows:
1.

This cause of action arises under federal statutes and jurisdiction is proper

under 28 U.S.C. section 1331.
2. Plaintiff files this Complaint under a pseudonym in order to protect her
identity because this Complaint makes allegations of a sensitive sexual nature the
disclosure of which, in association with her name, would cause further harm to her.

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3. At all times material to the events alleged in this cause of action the Plaintiff
was a citizen of South Africa residing in New York, New York.
4. At all times material to this cause of action Defendant Jeffrey Epstein had
multiple residences, including in New York, New York (within the Southern
District of New York) and the United States Virgin Islands. He is currently a
citizen of the United States and claims to be a resident of the U.S. Virgin Islands.
5. At all times material to this cause of action Defendant Jeffrey Epstein was an
adult male born in 1953.
6. At all times material to this cause of action Defendant Ghislaine Maxwell
was residing in in New York, New York and was a citizen of Great Britain and
France.
7. At all times material to this cause of action Sarah Kellen was a United States
citizen, residing in New York, New York (within the Southern District of New
York).
8. At all times material to this cause of action Lesley Groff was a United States
citizen, employed by New York based company and regularly conducting business
in New York, New York (within the Southern District of New York).
9. A substantial part of the acts, events, and omissions giving rise to this cause
of action occurred in the Southern District of New York; venue is proper in that
District. 28 U.S.C. section 1391(b)(2)
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10. At all times material to this cause of action, Defendants Jeffrey Epstein,
Ghislaine Maxwell, Sarah Kellen, and Lesley Groff owed a duty to Plaintiff to treat
her in a non-negligent manner and not to commit or conspire to commit
intentional, criminal, fraudulent, or tortious acts against her, including any acts in
violation of 18 U.S.C. §1595.
FACTUAL ALLEGATIONS
11. At all times material to this cause of action, Defendant Jeffrey Epstein was
an adult male over 50 years old. Defendant Epstein is widely recognized as a
billionaire who uses his extraordinary wealth to commit illegal sexual crimes in
violation of federal and state statutes and to employ and conspire with a group of
numerous others, including each of the named Defendants, to assist in committing
those crimes and additional torts as well as to conceal the crimes and torts of the
Epstein sex trafficking group from being discovered.
12. Defendant Epstein displays his enormous wealth, power and influence to his
employees; to the victims procured for sexual purposes; and to the public in order
to advance and carry out his crimes and torts. At all relevant times, Defendant
Epstein owned and continues to own, directly or through nominee individuals used
to conceal his interests, a fleet of airplanes, motor vehicles, boats and one or more
helicopters. For example, he owned (directly or indirectly) a Boeing aircraft (of
make and model B-727-31H with tail number N908JE) and a Gulfstream aircraft
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(of make and model G-1159B with tail number N909JE).

He also owned

numerous properties and homes, including a 51,000-square-foot mansion in
Manhattan; a $30 Million, 7,500-acre ranch in New Mexico; a 70-acre private
island formerly known as Little St. James in or near St. Thomas, U.S. Virgin
Islands; a home in Paris, France; and a mansion in Palm Beach County, Florida.
The allegations herein primarily concern the defendant’s conduct while at his
townhouse in New York; on one or more of his private airplanes; and on his
private island in the United States Virgin Islands. Epstein used all of the real and
personal property described in this paragraph to facilitate the illegal sex trafficking
venture and enterprise described in this Complaint and in furtherance of that
venture and enterprise.
13. Defendant Epstein has a compulsive sexual preference for young females as
young as 13 and as “old” as 25. Through information and belief Defendant Epstein
engages in sexual acts with this age range every day and developed, through the
employment of and conspiracy with the other Defendants, a sex trafficking venture
and enterprise designed to fulfill his sexual desires and conceal the operation of the
venture and enterprise and conduct of its participants. As part of the venture and
enterprise, Epstein also provided young females for sexual purposes to his friends
in order to secure social, business, and other contacts as well as other things of
value.
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14. Defendant Maxwell was for decades the highest-ranking employee of the
Defendants’ sex trafficking venture and enterprise. She herself recruited young,
including underage, females; oversaw and trained other recruiters on how best to
recruit girls for sex; developed and executed schemes designed to recruit young
females; and ensured that all participants of the Defendants’ sex trafficking scheme
acted in certain specific ways in order to advance the purposes of the scheme,
including providing young females to Epstein for sexual purposes on a daily basis,
and concealing these activities from law enforcement.
15. Defendant Kellen recruited young females for Epstein for sexual purposes,
brought gifts to females in order to entice those females to commit sex acts with
Epstein and to assist in concealing the illegal sexual conduct of the venture and
enterprise, and maintained Epstein's sex schedule in order to ensure that he was not
without young females for any extended period of time. Defendant Kellen also
handled travel arrangements for various females being exploited for sexual
purposes. Defendant Kellen was an integral part of the sex trafficking venture and
enterprise and reported directly up the enterprise’s line of authority to Defendants
Maxwell and Epstein.
16. Defendant Epstein employed many recruiters of young females. The nature
of the Defendants’ sex trafficking venture and enterprise enabled victims
themselves to elevate their status to that of a paid recruiter of other victims.
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Recruiters were taught by Defendants Epstein, Maxwell and Kellen to inform
targeted victims that Epstein possessed extraordinary wealth, power, resources and
influence; that he was a philanthropist who would help female victims advance
their careers and lives; and that the recruits needed only to provide Epstein with
body massages in order to avail themselves of his financial assistance and
influence. In fact, however, these representations were fraudulent. The young
females were actually required to perform intimate sexual acts at the Defendants’
direction and the Defendants did not help nor intend to help advance the victims’
careers. Victims were also paid to bring Epstein other young females for sex and
were told by Defendants Epstein, Maxwell, and Kellen that those young females
who brought other females would further benefit from bringing other girls.
17. Defendant Groff was an integral part of the illegal venture and enterprise.
Groff coordinated schedules between Defendant Epstein and the various young
females used for sex; made travel arrangements for the young females; tended to
the living needs of those females; communicated and coordinated with Defendants
Epstein, Maxwell and Kellen to assist in facilitating young females being available
in locations where the other Defendants were traveling; and she carried messages
to the young females from the other Defendants including false representations in
order to maintain the young females' compliance with the rules of sexual
compliance imposed by this structured sex-trafficking group. Groff was aware of
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the activities of the venture and enterprise, including the fraudulent representations
and other coercion that was being applied to secure the females’ compliance with
demands of sex.
18. The Defendants, led primarily by Defendants Epstein and Maxwell, fulfilled
Epstein’s compulsive need for sex with young females by preying on their
personal, psychological, financial, and related vulnerabilities. The Defendants’
tactics included promising the victims money, shelter, transportation, gifts,
employment, admission into educational institutions, educational tuition,
protection, and other things of value in exchange for sex. Defendants also took
possession of the victims’ passports to coerce compliance with their demands.
Defendants also trafficked young females to Epstein’s friends and acquaintances in
order to secure financial and other benefits as well as social, educational, and
business connections.
19. Defendants’ sex trafficking venture and enterprise operated in a hierarchal
structure with Defendants Jeffrey Epstein and Ghislaine Maxwell at the top.
Defendants Epstein and Maxwell operated the sex trafficking scheme dating back
to at least the mid-nineties, and over the years perfected their roles and the roles of
others, both in terms of the ability to increase the volume of young females
recruited for sex and in insulating the enterprise from criminal investigation or
prosecution. Defendant Groff conspired with Defendant Epstein and Maxwell
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since at least 2002 and continues to work for Defendant Epstein today. Defendant
Kellen began working with the Epstein-run sex trafficking venture and enterprise
as early as 2001 and her role in their venture and enterprise was well-defined and
primarily consisted of conspiring in the commission and cover-up of sex crimes.
Underlings included the other named Defendants as well as unnamed coconspirators such as various housekeepers and butlers; an airplane pilot; and
various employees, assistants and associates. Wittingly and unwittingly, such
underlings performed their respective roles with the purpose and effect of insuring
that the enterprise supplied young females to Defendant Epstein and others for
sexual purposes.

At all times materials to this complaint, the venture and

enterprise was a group of two or more individuals associated in fact and deed.
20. Defendants Epstein and Maxwell, with help from assistants, associates and
underlings, recruited and procured hundreds of girls over the decades of the
operation of their scheme. Such recruitment and procurement included fraud,
coercion, threats, intimidation, fear, the threat of coercion, and a combination of
these and similar tactics. Following the Defendants’ recruitment and procurement
of the young females to join Epstein in New York and the U.S. Virgin Islands, the
Defendants used fraudulent promises, coercion, and threats of coercion in order to
entice and coerce the females into sex and, once sexual activities ensued, to cause
them to remain in the enterprise.

The Defendants also transported females in
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interstate and foreign commerce and in ways that affected interstate and foreign
commerce. The sex acts were commercial in nature, because the Defendants
promised to provide financial and other compensation to the females in exchange
for providing sex acts to Epstein.
21. Defendants specifically targeted underprivileged, emotionally vulnerable
and/or economically disadvantaged young females to provide sex for Epstein.
22. Additionally, Defendants always made clear to every young female that they
were wealthy, well-connected and could either help or hurt the females depending
on their degree of cooperation. In fact, Defendants Epstein and Maxwell have
been known to threaten young females with physical harm. It is unknown exactly
how long the Defendants’ criminal and illegal venture and enterprise operated,
although it was at least continuously and actively in operation from the mid-1990’s
through and including the calendar year 2007.
23. Defendant Epstein has continued the venture and enterprise up to the present
time in some form or another and with additional co-conspirators and participants.
24. In 2005, Defendant Epstein and numerous co-conspirators within the venture
and enterprise were the subjects of a Palm Beach, Florida Police Department
criminal investigation which revealed that Defendant Epstein had engaged in
sexual activities with dozens of young teenage school children.

Each child

identified in that particular investigation was lured into Defendant Epstein’s Palm
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Beach mansion with a promise that she would receive money for providing him
with a body massage, although once there, each young female was made to engage
in sexual acts in order to receive the promised compensation. Several were also
made to engage in sex with another of Defendant Epstein's female traveling sex
companions who Epstein referred to as his lesbian sex slave and bragged about
purchasing her from her family when she herself was underage.
25. In 2006, the Palm Beach Police Department investigation was turned over to
the FBI and the United States Attorney's Office for the Southern District of
Florida. The United States Attorney's Office investigated Defendant Epstein and
his co-conspirators for their violations of numerous federal statutes, including 18
U.S.C. Section 1591, one of the statutory bases for this complaint.
26. The United States Attorney’s investigation continued from 2006 through
September 2007, at which time a Non-Prosecution Agreement was signed between
Jeffrey Epstein and the United States Attorney's Office deferring federal
prosecution of Defendant Epstein and his numerous co-conspirators, including
Defendants Kellen and Groff, each named by the Federal Government as coconspirators, for identified federal sex crimes against more than 30 minors.
27. From late 2006 through September 2007, Epstein's team of lawyers
negotiated with the federal government in an effort to avoid a fifty-three-page
Federal felony indictment from being filed against Epstein.
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negotiations, Defendant Epstein decamped from Palm Beach to New York and the
U.S. Virgin Islands in order to convey an image to prosecutors that he and his coconspirators had stopped committing sex crimes.
28. Remarkably, however—as this case will highlight—Defendant Epstein and
his co-Defendants, including the other defendants named herein, did not abandon
their sex trafficking venture and enterprise even while they were under state and
federal investigation for crimes committed in violation of 18 U.S.C. section 1591,
among other laws, and even as Defendants and their attorneys were busy arguing
Epstein’s innocence and publicly defaming his victims as liars. Rather, Defendants
merely changed their location. Instead of targeting local Palm Beach Florida
school girls, the Defendants transported young females from other places in the
U.S. (including the Southern District of New York) and abroad and brought them
to Defendant Epstein’s mansion in New York City and his private island in the
Virgin Islands.
29. In June of 2008, Epstein pleaded guilty to Florida state felony sex offenses
for procuring a minor for prostitution and soliciting prostitution by minors and
registered as a Sex Offender for Life.
30. Defendants

Epstein

and

Maxwell

developed

and

implemented

a

sophisticated system designed to insulate them from criminal and civil liability by
protecting them from potential testimony of knowledgeable subordinates.
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Defendants Kellen and Groff adapted to the system and also carried it out for years
in exchange for significant pay, benefits, and protection from prosecution. The
system included requiring subordinates to sign confidentiality agreements barring
disclosure of criminal activity; maintaining records of underage females who were
abused by Epstein; requiring subordinates and victims to refrain from speaking
with law enforcement officials; requiring them to notify Defendant Epstein’s
lawyers in the event they (subordinates and victims) were contacted by law
enforcement officials; requiring them to accept the representation of attorneys paid
for by Defendant Epstein; requiring them to invoke the Fifth Amendment in
response to questions they might be asked by investigators and prosecutors;
requiring them to invoke the Fifth Amendment in order to refuse to turn over
incriminating and non-incriminating evidence to law enforcement officers;
requiring them to destroy evidence or refuse to reveal knowledge of destroyed
evidence; and requiring them generally to refuse all cooperation with law
enforcement officials or investigations.
31. In 2005, Defendant Epstein and other co-conspirators, aware that law
enforcement officials were preparing imminently to execute a search warrant for
his home, removed computer systems that logged information about Epstein and
his co-conspirators' illegal and criminal conduct; the identities of witnesses; nude

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photographs of young females; scheduling books; message pads; tangible items
such as vibrators and toys; and other incriminating matter.
32. The sex recruiting and trafficking venture and enterprise designed to procure
young females for sexual purposes and to conceal those activities was developed
and fine-tuned over time, and each of the named Defendants had a well-defined
role and improved in his/her role over time, with practice and experience. By the
time Plaintiff was recruited into victimization, each Defendant had years of
experience perfecting methods of coercion, understanding Epstein's requirements,
and becoming more loyal to the continuance and survival of the venture and
enterprise. All of the Defendant’s knew about the activities of the venture and
enterprise and worked in concert for the goals of the venture and knowingly
benefitted, financially and by receiving things of value, from their participation in
the venture and enterprise.
33. A typical way the Defendants procured young females for sex with
Defendant Epstein was to make false promises of a modeling opportunity, offer a
better life, offer payment for a formal education, or offer other money or
consideration.
34. Beginning in approximately October 2006 and continuing through April
2007, Defendants recruited Plaintiff into their sexual enterprise by fraudulently

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promising to use their connections and resources to secure her admission to an
institution of higher education at the expense of Defendant Epstein.
35. One of the enterprise’s many recruiters, Natalya Malyshev, was working to
recruit young females for Epstein for sex when she approached and recruited
Plaintiff.
36. Malyshev informed Plaintiff that she would introduce Plaintiff to Defendant
Epstein, whom she described as a wealthy philanthropist who regularly used his
wealth, influence and connections to help financially poor females like Plaintiff
achieve their personal and professional goals and aspirations.
37. Malyshev reported to her superiors, Defendants Kellen, Groff and Maxwell,
and was paid for her recruitment of young females, including Plaintiff.
38.

Malyshev introduced Plaintiff to Defendant Epstein, who confirmed to

Plaintiff that he would use his wealth and influence to have Plaintiff admitted into
The Fashion Institute of Technology (known as “F.I.T.”) in New York City or into
a similar institute of higher learning offering a curriculum of fashion industry
training. Between October 2006 and May 2007, Defendants Maxwell, Kellen, and
Groff each also confirmed and reiterated this promise to Plaintiff many times, each
telling Plaintiff that Epstein would use his wealth and connections to advance
Plaintiff's education. More specifically, each of the Defendants last verified this
information that Epstein was using his connections to ensure Plaintiff was admitted
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into F.I.T. in exchange for Plaintiff’s continued sexual cooperation with Epstein in
March or April of 2007.
39. Defendant Maxwell told Plaintiff she would need to provide Defendant
Epstein with body massages in order to reap the benefits of his and Maxwell's
connections.
40. All Defendants, including Maxwell, Epstein, Groff and Kellen, knew that
Plaintiff was actually being recruited for sexual purposes, and each knowingly and
deliberately made false representations to ensure that Plaintiff would cooperate in
fulfilling Epstein’s sexual desires.

These false and fraudulent representations

included Defendants’ telling Plaintiff that Epstein would use his connections to
have her admitted into F.I.T. or a similar institute, college, university or school of
higher learning and provide her with employment opportunities.

Plaintiff

reasonably relied on these representations and had a credible basis for such
reliance, including the credible representations of Epstein and the other Defendants
that they possessed extensive political, business, financial, social, and educational
influence and connections.

Epstein and the other Defendants represented to

Plaintiff in manners that were persuasive, credible, and reasonable to Plaintiff, as
they would have been to any other person similarly situated, that they had the
political, business, financial, social, educational, and other influence and

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connections sufficient to arrange for and insure her admission into F.I.T. or a
similar school of higher learning.
41. Maxwell and Epstein also threatened Plaintiff that, while they had the ability
to advance her education and career, they also had the ability to make sure that
Plaintiff would not obtain formal education or modeling agency contracts if she
failed to provide the sexual favors desired by Defendant Epstein or abide by the
instructions given her by Defendants Epstein, Groff, Kellen and Maxwell.
42. Plaintiff reasonably believed that her compliance with Defendants’ demands
was crucial to her physical, psychological, financial, and reputational well-being
and survival.
43. Defendant Maxwell instructed Plaintiff how to massage Epstein using the
techniques that Maxwell knew that Epstein preferred.

During Plaintiff’s first

massage, Defendant Epstein converted it into a sexual act and made it known to
Plaintiff that further sex would be required in order for her to obtain the assistance
he promised her and to avoid Defendants’ threatened retaliation against her if
Plaintiff did not perform as demanded.
44. Maxwell and Epstein informed Plaintiff that other young females in
Epstein’s company were there also to perform sexual acts for Epstein and his
friends.

Groff and Kellen helped to secure the presence of the other young

females for these purposes.
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45. Plaintiff was instructed dozens of times to provide body massages to
Epstein, both at his townhouse in New York and on his private island in the U.S.
Virgin Islands. Each time she was so instructed she was also required to perform a
sexual act with Epstein. The Defendants all participated in arranging for Plaintiff
to be transported in interstate and foreign commerce, and affecting interstate and
foreign commerce, for these sexual purposes. The Defendants Epstein, Maxwell,
and Kellen used possession and control of Plaintiff’s passport to induce and coerce
Plaintiff into performing sexual acts with Epstein and others.
46. During many sexual encounters, Defendant Epstein gave Plaintiff no option,
opportunity, or choice not to participate in the prescribed sexual acts.
47. Defendant Maxwell frequently controlled the assignment, or “rotation,” of
Plaintiff and the other young females concerning the time, place and manner of the
sex acts they were told to provide to Defendant Epstein. Defendant Maxwell also
gave instructions on how to perform certain sexual techniques on Epstein.
Defendants Maxwell and Epstein also required Plaintiff to engage in sex acts with
other females.
48. Defendants Epstein and Maxwell intimidated, threatened, humiliated and
verbally abused Plaintiff in order to coerce her into sexual compliance. These
Defendants threatened Plaintiff with serious harm, as well as serious

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psychological, financial, and reputational harm, compelling Plaintiff to perform
and continue performing the commercial sexual activity demanded by Defendants.
49. On one occasion, after suffering verbal abuse and threats by Defendants
Epstein, Maxwell, and Kellen, Plaintiff attempted to escape from Defendant
Epstein’s private island. A search party led by Defendants Epstein and Maxwell
located her and physically returned her to the main house on the island. Through
these and other actions, the Defendants intended to cause, and did cause, Plaintiff
to believe that failure to perform the actions they requested would result in
physical restraint and potential harm to her person, as well as harm to her
reputation, employability, and stable state of mind.

Defendants further used

possession and control of Plaintiff’s passport, without lawful consent or authority,
to restrict Plaintiff’s liberty and thereby force her to provide sex to Epstein.
50. Defendant Epstein’s wealth, influence, power and connections were used by
Defendants Maxwell, Kellen, and Groff, both as an inducement to provide sex (in
exchange for promises of support to Plaintiff) and as a means of threatening
punishment (in the event Plaintiff refused to comply with Defendants’ instructions
to provide sex to Epstein and others).
51. In addition to Plaintiff’s being trafficked on Epstein’s private airplane,
Defendants Groff, Maxwell and Kellen, with the knowledge of and instruction by
Defendant Epstein, arranged Plaintiff's living accommodations, private car travel,
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and commercial air travel on numerous occasions for the purpose of causing
Plaintiff to commit commercial sex acts. These Defendants worked in concert with
one another to recruit, procure, entice, and otherwise cause many other females to
engage in commercial sex acts, through their use of threats, fraud, and coercion.
Among these means of coercion were the Defendant’s possession and control of
the females’ passports and other immigration documents. This coercion was most
salient, and especially effective, while the females, including Plaintiff, were on
Epstein’s island.
52. In furtherance of their venture and enterprise, Defendants provided living
quarters for Plaintiff at 301 East 66th Street, New York, in the Southern District of
New York; a car service for Plaintiff to use as needed; a cell phone; and other
valuable consideration in order to maintain Plaintiff's sexual compliance. Each of
the Defendants told Plaintiff she would obtain the benefits of a place to live and
phone and transportation as long as she remained compliant with their demands
that she service Epstein sexually. Each of the Defendants also told her that if she
was not compliant, these benefits would be taken from Plaintiff.
53. The relationship between Plaintiff and Defendants Epstein and Maxwell was
defined and characterized by Defendant Epstein’s and Defendant Maxwell’s
frequent and persistent fraudulent representations that they would provide Plaintiff
with a formal education and career advancement if she provided sex to Defendant
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Epstein and others in the times, places and manners demanded by Defendants.
Defendants Groff and Kellen each also told Plaintiff that Defendant Epstein would
advance Plaintiff's education and career in order to coerce Plaintiff into sex.
Defendant Kellen told Plaintiff that Epstein had done the same for her career. As a
result of these and other representations by Defendants, Plaintiff reasonably relied
on these representations. In fact, however, these representations were knowingly
false, were not acted upon by Defendants, and were made by Defendants Epstein,
Groff, Kellen, and Maxwell solely for the purpose of maintaining Plaintiff's
financial dependence on, emotional vulnerability to, and sexual compliance with
Defendant Epstein’s demands. The other Defendants intentionally repeated these
representations and intentionally made statements designed to convince Plaintiff
that the representations were true and could be relied upon. These representations
and statements were made to Plaintiff in furtherance of the sex trafficking venture
and enterprise for which they were each employed.
54. As part of the venture and enterprise, Defendants Epstein, Maxwell, and
Kellen took possession of Plaintiff’s passport when she was being trafficked by
them, including when she travelled to Epstein’s island in the U.S. Virgin Islands.
The Defendants took possession of Plaintiff’s passport in the course of sexually
trafficking Plaintiff and with the intent to violate laws against sex trafficking,
including 18 U.S.C. 1591 et. seq. The Defendants used their control of Plaintiff’s
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passport in order to coerce compliance with their demands, including their
demands that Plaintiff have sex with Epstein and others.
55. In January 2007, as part of their illegal venture and enterprise, Defendants
sent Plaintiff from New York City, in the Southern District of New York, to South
Africa to recruit, for a promised fee, one or more aspiring female models
supposedly for Epstein to use as a personal assistant. The Defendants did not care
whether the prospective female was qualified to work as a personal assistant
because each knew that the female recruit would be immediately placed into the
same sexually vulnerable position as Plaintiff (and the dozens of other victims of
the sex trafficking enterprise) and would be induced and coerced into being used
for sex through fraudulent representations and other means.
56. Defendants Epstein and Maxwell continuously and frequently demanded
that Plaintiff fulfill this task of bringing another female back to the United States
and Defendants’ control as a condition of Plaintiff’s receiving the education, career
and related benefits promised by Defendants Epstein and Maxwell. Based upon
Plaintiff’s experience with Defendants, however, she knew that the requested
female model would not be placed in a legitimate position of employment with
Defendant Epstein but would, instead, be forced into sexual servitude. Plaintiff
also knew that this objective was the only purpose of Defendants Kellen, Groff,

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Maxwell and Epstein’s demand for Plaintiff’s recruitment efforts. As a result,
Plaintiff deliberately refused to perform the recruitment assignment.
57. As part of their ongoing scheme, Defendants inflicted serious emotional and
psychological harm on Plaintiff as a means of coercing her to continue engaging in
commercial sex acts with Epstein and others. While Plaintiff was in South Africa,
Defendants Epstein and Maxwell informed Plaintiff that she would not be
permitted to return to the United States to receive her promised education unless
she underwent a diet and lowered her body weight from 57 kilograms
(approximately 125 pounds) to 52 kilograms (approximately 114 pounds). Epstein
and Maxwell promised Plaintiff that, if she complied, she would receive her
promised education.

Defendant Groff monitored Plaintiff's progress in losing

weight and continued to communicate with Plaintiff about Plaintiff’s application to
be admitted into F.I.T. as part of the Defendants’ ruse to coerce Plaintiff to return
to the United States for sex. Defendant Groff was aware of the coercion Epstein
and Maxwell were applying to Plaintiff and acted to help further that coercion.
Believing she had no practical choice in the matter, Plaintiff attempted to comply
with the order but, given her physical height and body structure and her already
existing body weight, the diet imposed upon her placed her in serious physical
jeopardy, including kidney malfunction and extreme emotional and psychological
distress.
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58. As part of their scheme, Defendants Epstein and Maxwell called Plaintiff’s
parents in South Africa to tell them that Defendant Epstein would take good care
of Plaintiff when she returned to the United States, and that Defendants Maxwell
and Epstein would use their connections and influence to have her admitted to
F.I.T. or another well-regarded fashion school or school of higher learning.
59.

As part of their scheme, Epstein and Groff told Plaintiff that she should fill

out an application for admission to F.I.T., and supporting essay, and send it to
Epstein for his review. Pursuant to these instructions, Plaintiff completed an
application, and supporting essay, and sent it to Epstein. As part of his scheme,
Epstein told Plaintiff that he had reviewed these materials. His statements were
intended to convince Plaintiff, and had the effect of convincing plaintiff (as they
would have convinced any reasonable person), that her admission to F.I.T. was a
“done deal” if she would comply with his instructions. Groff also made the same
representations to plaintiff on Epstein’s behalf. Plaintiff reasonably relied on these
representations by Epstein and Groff.
60. As part of their scheme, Epstein and Maxwell told Plaintiff that they had
contacts at F.I.T. and at modeling agencies who could ensure her admission to
F.I.T. and advance Plaintiff’s career.

As part of their scheme, Epstein and

Maxwell told Plaintiff about Epstein’s vast wealth and specifically identified him
as a billionaire.

Epstein and Maxwell told Plaintiff that they had extensive
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contacts, in addition to those identified above, throughout New York City and
elsewhere.
61. In February of 2007, in reliance on promises made by the Defendants,
Plaintiff returned to New York City, in the Southern District of New York, and
was promptly ordered by Defendant Maxwell to have sex with Defendant Epstein.
Defendants Maxwell, Kellen, Groff, and Epstein each fraudulently promised
Plaintiff again that her sexual compliance would be rewarded with admission to
F.I.T. or a comparable college, a promise which they each knew to be false. In fact
all four Defendants had for years worked solely to recruit females for sex and to
conceal the operation of the sex scheme, and in 2007 were under Federal
investigation for their conspiracy to engage in Federal sexual crimes like those
committed against Plaintiff. Plaintiff knew that if she did not comply, Defendants
Maxwell and Epstein would use their power, influence and connections in order to
ensure that Plaintiff was unable to gain admission to F.I.T. or a comparable school,
and that they would destroy her career, just as they had destroyed the careers of
others who had failed to comply with their demands.
62. Defendants Epstein and Maxwell continued to provide Plaintiff with things
of value in exchange for Plaintiff’s continued compliance with Epstein’s sexual
demands; however, they failed and refused to perform their promises to help
Plaintiff be admitted to F.I.T. or another school, or to provide financial support for
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college admission or on-going education, false promises they repeatedly made in
order to coerce her into commercial sex acts.
63. Defendants’ sexual demands on Plaintiff continued while she was in New
York City, in the Southern District of New York, or in other locations in close
proximity to the Defendants. In addition to their requiring Plaintiff to provide
Defendant Epstein with sex acts, each of the Defendants continued to pressure her
to lose excessive amounts of body weight and offered her no opportunity to decline
or resist their instructions.
64. In May, 2007, Plaintiff left the United States and did not return. Between
returning from South Africa in February 2007 and leaving in May 2007,
Defendants Kellen, Groff, and Maxwell each continued to repeatedly make false
representations to Plaintiff, including false and fraudulent representations that she
would be admitted to F.I.T. if she continued to engage in sex with Epstein.
Defendant Epstein continued to make similar false and fraudulent promises in
order to have sex with Plaintiff.
65. In and after May 2007, Defendants actively concealed and covered up what
they had done to Plaintiff and other similarly situated females. Defendant’s coverup included efforts to intimidate witnesses who might provide corroborating
testimony to Plaintiff as well as destruction of documents and other evidence
regarding what they had done.
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66. Unknown to Plaintiff, Defendants’ representations and promises to Plaintiff
were all false and fraudulent. Plaintiff reasonably relied on the representations and
promises of the Defendants. Plaintiff also considered the Defendants’ threats
against the current and future well-being and safety of Plaintiff to be real and
credible. All such representations, promises, and threats were made solely for the
purpose of coercing and otherwise inducing Plaintiff into prolonged sexual
compliance. Defendants knowingly benefitted financially and received things of
value as a result of coercing and inducing Plaintiff into sexual compliance and
otherwise participating in their illegal venture and enterprise.
COUNT I
CAUSE OF ACTION AGAINST DEFENDANTS PURSUANT TO 18 U.S.C.
§ 1595
67. Plaintiff adopts and realleges paragraphs 1 through 66 above.
68. Defendants individually and together, within the special maritime and
territorial jurisdiction of the United States, in interstate and foreign commerce,
and/or affecting interstate and foreign commerce, knowingly recruited, enticed,
harbored, transported, provided, maintained, patronized, solicited, threatened,
forced, and coerced Plaintiff to engage in commercial sex acts. Such actions by
Defendants were undertaken with knowledge and/or reckless disregard of the fact
that their threats of force, fraud, coercion, and combinations of such means would

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be used, and were in fact used, in order to cause Plaintiff to engage in commercial
sex acts. In so doing, Defendants violated 18 U.S.C. §1591.
69. Additionally, Defendants Epstein, Maxwell, and Kellen, individually and
together, knowingly concealed, removed, confiscated, and possessed Plaintiff’s
passport and associated immigration documents, in the course of violating 18
U.S.C. § 1591, and with the intent of violating 18 U.S.C. § 1591, and to prevent,
restrict, attempt to restrict, without lawful authority, Plaintiff’s liberty to move or
travel, in order to maintain the sexual services of Plaintiff, while Plaintiff was a
victim of a severe form of sex trafficking, as defined in section 103 of the
Trafficking Victims Protection Act of 2000, enacted in 22 U.S.C. § 7102. In so
doing, Defendants violated 18 U.S.C. § 1592. These Defendants also obstructed,
and attempted to obstruct and to interfere with the enforcement of 18 U.S.C. §
1592.
70. Additionally, Defendants knowingly benefitted, financially and by receiving
things of value, from participating in a venture (the Epstein sex trafficking venture
enterprise) which had engaged in acts in violation of 18 U.S.C. § 1592 and
1595(a), knowing that the venture had engaged in such violations. In so doing,
Defendants violated 18 U.S.C. § 1593A.
71. Additionally, Defendants attempted to violate 18 U.S.C. § 1591. In so
doing, Defendants violated 18 U.S.C. § 1594(a).
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72. Additionally, Defendants conspired with each other, and with other persons
known and unknown, to violate 18 U.S.C. § 1592.

In so doing, Defendants

violated 18 U.S.C. § 1594(b).
73. Additionally, Defendants conspired with each other, and with other persons
known and unknown, to violate 18 U.S.C. § 1591.

In so doing, Defendants

violated 18 U.S.C. § 1594(c).
74. By virtue of their violations of 18 U.S.C. §§ 1591, 1592, 1593A, and 1594,
Defendants are subject to civil causes of action under 18 U.S.C. § 1595 by
Plaintiff, who is a victim of their violations.
75. Certain property of Defendant Epstein's was essential to the commission of
the federal crimes and torts described herein, including the use of multiple private
aircraft including a Boeing aircraft (of make and model B-727-31H with tail
number N908JE) and a Gulfstream aircraft (of make and model G-1159B with tail
number N909JE). Such aircraft, along with other of Defendants’ property, were
used as means and instruments of Defendants’ tortious and criminal offenses and,
as such, are subject to forfeiture.
76. Additionally, Defendant Epstein’s New York mansion, located at 9 East 71st
Street, New York, New York, in the Southern District of New York, and his
private island located in the United States Virgin Islands, were used as means and

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instruments of Defendants’ tortious and criminal offenses and, as such, are subject
to forfeiture.
77. As a direct and proximate result of Defendants’ commission of the
aforementioned criminal offenses enumerated in 18 U.S.C. § 1591, 1592, 1593A,
and 1594, and the associated civil remedies provided in § 1595, Plaintiff has in the
past suffered and will continue to suffer injury and pain; emotional distress;
psychological and psychiatric trauma; mental anguish; humiliation; confusion;
embarrassment; loss of self-esteem; loss of dignity; loss of enjoyment of life;
invasion of privacy;

and other damages associated with Defendants' actions.

Plaintiff will incur further medical and psychological expenses. These injuries are
permanent in nature and Plaintiff will continue to suffer from them in the future.
In addition to these losses, Plaintiff has incurred attorneys’ fees and will be
required do so in the future.
WHEREFORE, Plaintiff demands judgment against Defendants for
compensatory and general damages, attorney’s fees, punitive damages and such
other and further relief as this Court deems just and proper. Plaintiff hereby
demands trial by jury on all issues triable as of right by a jury.
Dated: June 5, 2017.
Respectfully Submitted,
FARMER, JAFFE, WEISSING. EDWARDS,
FISTOS, LEHRMAN, P.L.
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By: /s/ Bradley J. Edwards
Bradley J. Edwards
425 N. Andrews Ave., Suite 2
Fort Lauderdale, FL 33301
(954)-524-2820
Fax: (954)-524-2822
Email: brad@pathtojustice.com
PRO HAC VICE
BOIES, SCHILLER & FLEXNER LLP
David Boies
Boies Schiller & Flexner LLP
333 Main Street
Armonk, NY 10504
(919) 749-8200
Fax: (914) 749-8300 Email: dboies@bsfllp.com
Sigrid McCawley
Meredith Schultz
Boies Schiller & Flexner LLP
401 East Las Olas Blvd., Ste. 1200
Fort Lauderdale, Florida 33301
(954) 356-0011
Fax:
Email: smccawley@bsfllp.com
Email: mschultz@bsfllp.com
PRO HAC VICE
Paul G Cassell
S.J. Quinney College of Law at the University of
Utah
383 S. University Street
Salt Lake City, UT 84112-0730
(801)-585-5202
Fax: (801)-585-2750
Email: cassellp@law.utah.edu *
PRO HAC VICE

*

This daytime business address is provided for identification and correspondence purposes only and is
not intended to imply institutional endorsement by the University of Utah for this private representation

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CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 5th day of June, 2017, I electronically filed the
foregoing document with the Clerk of Court by using the CM/ECF system. I also certify that the
foregoing document is being served this day on the individuals identified below via transmission
of Notices of Electronic Filing generated by CM/ECF.

STEPTOE & JOHNSON, LLP
Michael C. Miller
Justin Y.K. Chu
mmiller@steptoe.com, cjenkins@steptoe.com, pparker@steptoe.com
jchu@steptoe.com, cjenkins@steptoe.com, pparker@steptoe.com, psafirstein@steptoe.com
Attorneys for Defendants
Jeffrey Epstein & Lesley Groff
ALSTON & BIRD, LLP
John E. Stephenson, Jr.
Alexander S. Lorenzo
alexander.lorenzo@alston.com, autodocket-nyc@alston.com,
managingclerksoffice-nyc@alston.com, john.stephenson@alston.com
Attorneys for Defendant Sarah Kellen
By: /s/ Bradley J. Edwards

31